A recent retroactive German law change has significantly increased Commerzbank's additional loss-absorbing capacity buffer, which should protect more-senior creditors in a resolution scenario. We are therefore raising our long-term issuer credit rating on Commerzbank AG to 'A-' from 'BBB+'. We are raising to 'A-' from 'BBB+' the issue ratings on instruments that we continue to view as senior unsecured debt under the new law, and lowering to 'BBB' from 'BBB+' the issue ratings on instruments that we have reclassified as senior subordinated debt. The negative outlook on Commerzbank reflects that we might lower our ratings if economic risks in Germany were to worsen within the next two years. On March 28, 2017, S&P Global Ratings raised its long-term counterparty credit